2014年-EBA欧洲银行管理局_Transparency_AR2009_32页_343kb

Summary of CEBS Report on Banks' Transparency in 2009 Audited Annual Reports

Core Content

This report, published on 30 June 2010, is part of a series of assessments by the Committee of European Banking Supervisors (CEBS) on banks' transparency, initiated in response to the global financial crisis that began in 2007. The focus is on the 2009 audited annual reports of European (mainly EU) banks and, in some cases, non-European banks. The assessment aims to evaluate how well banks have communicated the impact of the crisis on their operations, financial position, and risk management practices.

The report highlights that the CEBS June 2008 good practices have been generally well covered in the 2009 disclosures, particularly in areas such as business models and risk management. However, certain areas still require improvement, especially in terms of clarity, detail, and comparability.

Main Findings

1. General Perspective

• Business Models:

  • 71% of banks provided adequate disclosures on their business models, which were clear and easy to read.
  • 21% had room for improvement, and 8% provided insufficient information.
  • Some banks improved their disclosures compared to the previous year, while others remained similar or less detailed.
  • Areas for potential improvement include the implications of government support withdrawal and the granularity of product descriptions.

• Best Practice Examples:

  • Banks like Rabobank, Erste Bank, SEB, Dexia, RBS, and ING were cited for their clear and structured disclosures.
  • These examples demonstrate that quality is not necessarily linked to the quantity of disclosures.

2. Risks and Risk Management

• Assessment:

  • 83% of banks provided adequate disclosures on risks and risk management, while 17% had room for improvement.
  • All banks identified essential risks and gave qualitative descriptions of their risk management practices.
  • Some banks included information on changes in risk management practices due to the financial crisis, such as revised lending policies and enhanced stress testing.

• Best Practice Examples:

  • Santander and HSBC were noted for clear executive summaries and comprehensive discussions on risk management.
  • Disclosures on liquidity risk management improved in some banks, with a few publishing regulatory liquidity ratios and more detailed quantitative information.

3. Accounting Policies

• Valuation Issues:

  • CEBS identified that 58% of banks had room for improvement in fair value disclosures, while 38% provided adequate information.
  • The mandatory application of IFRS 7 amendments in 2009 led to better structured disclosures, especially regarding fair value hierarchy and level 3 instruments.
  • However, some areas, such as sensitivity analysis and valuation techniques, still lacked sufficient detail.

• Best Practice Examples:

  • Nordea, Crédit Agricole, and Société Générale provided detailed information on the fair value hierarchy by financial instrument class.
  • ING and BNP Paribas included comparative information and adjustments to 2008 figures.
  • UBS and RBS explained significant movements of level 3 instruments, and Nordea and Unicredit clearly distinguished between unrealised and realised gains and losses.

• Level 3 Disclosures and Sensitivity Analysis:

  • Most banks provided detailed level 3 disclosures, but some failed to disclose changes due to purchases, sales, and transfers.
  • Sensitivity analysis was generally lacking, with only a few banks providing detailed information on the impact of alternative assumptions.
  • Best practices included tabular presentations of potential impacts, clear assumption descriptions, and explicit statements on insignificant changes.

• Valuation Techniques:

  • Most banks provided generic information on valuation methods.
  • Some banks, like HSBC and Intesa, described valuation techniques for products using unobservable inputs.
  • Further specification of assumptions and inputs would enhance comparability.

4. Other Areas for Improvement

• Impairment Disclosures:

  • Banks could be more specific regarding methodologies used for collective impairment.
  • The quality and structure of these disclosures were heterogeneous.

• Reclassifications:

  • Reasons for reclassifications were often too generic, especially for banks that reclassified instruments in 2009.

• Consolidation and Derecognition:

  • There is room for improvement in how the risks and rewards test is conducted and presented.

• Disclosures on Activities Under Stress:

  • Specific activities such as consumer lending and private equity investments require more detailed disclosures.

5. Remuneration Disclosures

• CEBS noted that quantitative disclosures on remuneration schemes for staff with significant risk impact could be significantly improved.
• These disclosures are aligned with the Financial Stability Board's April 2009 principles on sound compensation practices, which are still being implemented in many countries.

Presentation and Structure Issues

• The quality of disclosures is not always correlated with the quantity, and some concise reports demonstrated good practice.
• The report also discusses the importance of presentation and structure in enhancing transparency and comparability.
• CEBS has developed best practice examples to assist banks in improving their disclosures, which are not exhaustive but are considered particularly useful.

Conclusion

CEBS continues to monitor banks' disclosures and has developed disclosure principles based on lessons learned from the financial crisis. The report serves as a guide for improving transparency and comparability, with a focus on areas such as fair value, impairment, reclassifications, and remuneration. The findings are intended to provide useful feedback to banks and promote better disclosure practices across the industry.